MG INDUSTRIES - MORRISVILLE,PA - Executive Summary

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MESSER - MG INDUSTRIES 
 
Morrisville, PA Cylinder Gas Production Plant 
 
RMP Executive Summary 
 
Introduction - Messer America's Loss Prevention Program  
 
Loss prevention management refers to the prevention of potential losses to Messer through an effectively designed, administered and implemented Environmental, Health, Safety and Regulatory Compliance Program. 
 
Incorporating an effective loss prevention program requires developing and integrating programs that will assist in reducing losses from accidents. Messer GmbH has developed Safety, Health and Environmental guidelines that have been incorporated in a comprehensive program defined as Loss Prevention Policies. These policies are the minimal standards for Messer America's operations, including the Morrisville, PA cylinder gas production facility. 
 
The objective of the program is to achieve an acceptable level of performance in the prevention of the losses to the organization which include but are not limited to accidents, injuries,  
illnesses, product liabilities and regulatory non-conformities. To be effective, this management system must be totally integrated in which all levels of employees are involved and held accountable. 
 
The ultimate authority for instituting an effective Loss Prevention Program rests with the senior management of each operating group. Through their words and more importantly through their actions, senior management sets the tone for loss prevention throughout Messer Americas. While senior management set the tone, middle management must create the uniform support and nurture the desired culture to influence the Loss Prevention Program. This strong management commitment culminates with the day to day responsibilities of implementing and managing the Loss Prevention Program by 'line management' (supervisors and lead personnel). Local management is accountable for the effective management of this program through their organization's performance as related to loss prevention and regulatory com 
pliance. 
 
In healthy loss prevention culture, each member of the company participates fully in the program. Loss prevention is no longer an activity that someone else is in charge of. Each manager, supervisor, driver and line worker is personally responsible for insuring 'safe working conditions, safe product for all customers and a safe environment for the citizens of the communities in which Messer operates'. 
 
Simplified Process Description 
 
MG Industries' cylinder gas plant in Morrisville, PA fills industrial and specialty gases in compressed gas cylinders. As part of the operation, large quantities of chemicals are stored in bulk tanks or large cylinders for transfilling to smaller cylinders or for making specialty gas mixtures. Of all the chemicals inventoried in the Morrisville plant, only the following chemicals come under Risk Management Plan (RMP) regulations: propane, propylene, ammonia anhydrous, chlorine, hydrogen chloride anhydrous and sulfur dioxide.  
 
 
GAS 
 
Ha 
zard 
Type 
Facility 
Aggregate Qty 
(pounds) 
 
Threshold Qty 
(pounds) 
 
Propane 
Propylene 
Ammonia (anhy.) 
Chlorine 
Hydrogen Chloride (anhy.) 
Sulfur dioxide (anhy.) 
 
 
Flammable 
Flammable 
Toxic 
Toxic 
Toxic 
 
Toxic 
 
66000 
36000 
17650 
12420 
12260 
 
5470 
 
 
10000 
10000 
10000 
2500 
5000 
 
5000 
 
All the processes in this facility come under Program 3 of the RMP regulations 
 
 
Worst Case Scenarios 
 
Flammables: Propane and propylene are stored in pressurized storage tanks, adjacent to each other. Because of their proximity to each other, they will be considered to be part of a single process. The default meteorological conditions were assumed and the consequence distances were obtained from the tables given in Off-site Consequence Analysis Guidelines (OCAG) for an unmitigated release of the entire contents of both the pressurized storage tanks in 10 minutes. The consequence distance was estimated as 0.37 miles, which impacts the neighboring commercial and industrial facilities. The Landview III softwa 
re package was utilized to determine the general environmental and community impact. There was no impact on any environmental receptor and there was minimal impact on public receptors. 
 
Toxic :  The worst case release scenario for all the toxic gases were calculated using the CAMEO program. Mr. Raymond Hackman of the Bucks County Haz-Mat Team in Doylestown, PA ran the program for the worst case scenarios we provided. The results for the unmitigated release of chlorine was reported since the chlorine release was considered to have the severest off-site impact. The largest quantity of chlorine in a single process vessel is 150 lbs and the worst case scenario was calculated based on default meteorological conditions and the release of the entire contents of the cylinder in 10 minutes. The consequence distance was estimated as 0.5 miles, which impacts the neighboring commercial and industrial facilities. The Landview III software package was utilized to determine the general environmental  
and community impact. There was no impact on any environmental receptor and there was minimal impact on public receptors. 
 
Alternate Case Scenarios 
 
Calculations for the estimation of the consequence distance were done for all the alternate case scenarios. Default meteorological conditions were assumed for all the cases. A task force consisting of employees with different job responsibilities and technical knowledge within the plant was put together. This task force identified, analyzed and evaluated different alternate case scenarios for each of the regulated flammable and toxic materials and then chose the 'most likely scenario' for each of the chemicals that would result in a release. 
 
Flammables: The storage of propane and propylene is considered to be a single process due to the proximity of the two pressurized storage tanks. Seven different alternate case scenarios were identified, analyzed and discussed by the task force. The 'transfer hose failure' was chosen to be the most li 
kely alternate scenario for this process. For flammables, the tables from the OCAG were used to estimate the consequence distance. For the alternate case scenario chosen, the consequence distance was estimated as 0.1 miles, which impacts the neighboring commercial and industrial facilities  
 
Toxic: As per the Program 3 requirement, at least one alternate case release scenario for each of the regulated toxic chemicals was reported. Calculations for all the alternate cases identified were done using the CAMEO program. Mr. Raymond Hackman of the Bucks County Haz-Mat team in Doylestown, PA ran the program for the various release scenarios we provided. The Landview III software package was utilized to determine the general environmental and community impact. There was no impact on any environmental receptor and there was minimal impact on public receptors.  
 
Chlorine : Five different alternate scenarios were identified, analyzed and discussed by the task force. The task force chose 'release 
through a cylinder valve safety' as the 'most likely scenario' for the storage and handling of chlorine cylinders. The consequence distance was estimated as 0.1 miles, which impacts the neighboring commercial and industrial facilities. The Landview III software package was utilized to determine the general environmental and community impact. There was no impact on any environmental receptor and there was minimal impact on public receptors. 
 
Hydrogen Chloride (anhydrous): Five different alternate scenarios were identified, analyzed and discussed by the task force. The task force chose 'release through a cylinder valve safety' as the 'most likely scenario' for the storage and handling of hydrogen chloride cylinders and 600 lb large containers. The consequence distance was estimated as 0.1 miles, which impacts the neighboring commercial and industrial facilities. The Landview III software package was utilized to determine the general environmental and community impact. There was no impac 
t on any environmental receptor and there was minimal impact on public receptors. 
 
Sulfur dioxide (anhydrous): Five different alternate scenarios were identified, analyzed and discussed by the task force. The task force chose 'release through a cylinder valve safety' as the 'most likely scenario' for the storage and handling of sulfur dioxide cylinders. The consequence distance was estimated as 0.1 miles, which impacts the neighboring commercial and industrial facilities. The Landview III software package was utilized to determine the general environmental and community impact. There was no impact on any environmental receptor and there was minimal impact on public receptors.  
 
Ammonia (anhydrous): Five different alternate scenarios were identified, analyzed and discussed by the task force. The task force chose 'pin hole leak through the walls or the foot ring of the cylinder' as the 'most likely scenario' for the storage and handling of ammonia cylinders. The consequence distance was  
estimated as 0.1 miles, which impacts the neighboring commercial and industrial facilities. The Landview III software package was utilized to determine the general environmental and community impact. There was no impact on any environmental receptor and there was minimal impact on public receptors. 
 
General Accidental Release Prevention Program  - Loss Prevention Written Policy 
 
Summary  
 
The objective of the Messer Loss Prevention Program is to achieve an acceptable level of performance in the prevention of losses to the organization. The paramount importance of our Loss Prevention Program is assuring safe working conditions of our employees, safe product for customers and a safe environment for the citizens of the communities in which we operate. The program is integrated with a series of  Loss Prevention Policies that are the cornerstone of Messer Loss Prevention efforts. These policies form our Loss Prevention Policies manuals. These manuals are maintained by local management and a 
re available for review by any employee upon request during normal business hours. In addition, compliance with local and federal regulations such as DOT, FDA and EPA are required. 
 
Authority and Responsibility for Program Implementation 
 
The Plant Manager has the overall site authority for implementation of the Loss Prevention Program. He or she is responsible for the day to day management of the Loss Prevention Policies as they directly relate to all operational activities. 
 
The Site Safety Advisor is responsible for conducting periodic inspections, serving as the facility spokesperson on loss prevention issues and participation on the safety committee. 
 
System for Identifying, Evaluating and Preventing Safety and Health Hazards 
 
The system for identifying, evaluating and preventing occupational safety and health hazards has been defined throughout the Loss Prevention Manual and this includes, but not limited to: 
 
- Review of applicable standards to the industry 
- Review and availabi 
lity of Material Safety Data Sheets (MSDSs) 
- Ensure the proper labeling of potentially hazardous materials 
- Safety work permitting systems 
- Investigation of accidents and incidents 
- Periodic and scheduled inspection of the general work areas. 
 
Employee Communications and Training 
 
Employee communications and training are also defined throughout the Loss Prevention Manual and these include but not limited to: 
 
- Monthly poster program service by the National Safety Council on a variety of safety and health topics 
- Site specific Safety Bulletin Board for posting all environmental, health and safety related information such as Loss Prevention Policy and safety posters 
- Site specific safety committee made up of representative functional positions within the operation 
- Monthly safety meetings held on various environmental, health and safety topics 
- Safety orientation of all new hires and personnel transferred into new positions 
- Regulatory compliance training as it may apply to spe 
cific operations and/or exposures such as hearing conservation, HAZCOM (HAZard COMmunications), respiratory protection and fire extinguishers. 
 
Process Safety Features 
 
This facility is manned 24 hours/day each week with routine in-house inspections by plant employees or on-site guard service. The plant has an evacuation plan based on a three level alarm system of lights and audible signals. The plant has a LEL (Lower Explosive Limit) monitoring system and a toxic gas monitoring system installed at appropriate work areas. The propane and propylene storage tanks are protected with sprinklers and have excess flow shut off protection. All toxic chemicals are transferred or blended in fume hoods that are vented into 'permitted' scrubber units. All of the RMP processes come under Process Safety Management (PSM) rules and have been reviewed and audited in the past year.          
 
Five Year Accident History 
 
There were no accidental releases of any of the RMP regulated chemicals from th 
e MG Industries cylinder gas plant in Morrisville, PA during the past five years. 
 
Emergency Response Program 
 
MG Industries has a state qualified and extensively trained emergency response team consisting of 14 members. This team currently responds to any customer site if a MG Industries product cylinder is involved. The team captains also meet quarterly with local municipality response organizations and other local industrial gas companies to review joint capabilities for responding to both on-site and off-site incidents.  All our emergency programs are coordinated with the Bucks County Emergency Planning authorities, the Bucks County LEPC and the Falls township Fire Marshall.  
 
Planned Changes to Improved Safety 
 
MG Industries is committed to continually improving our safety performance for all the operating units of the business. This is reflected in our 'Loss Prevention Policy' which states ' ..... MG is committed to steadily improving it's performance in this area and ulitmately  
to gaining a position among the very safest companies in the various communities in which we operate'.
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